Justia Ohio Supreme Court Opinion Summaries

Plaintiff filed a declaratory-judgment action against Defendant, seeking to quiet title to a mineral interest. At issue between the parties was whether the 1989 version of the Dormant Mineral Act or the 2006 version of the Act applied in this case. The trial court granted summary judgment in favor of Plaintiff. The court of appeals affirmed, concluding that the 1989 version of the Act applied, and therefore, Defendant, the owner of the severed mineral estate, did not preserve his rights. The Supreme Court reversed, holding (1) pursuant to Corban v. Chesapeake Exploration, LLC, the 2006 version of the Act applied in this case; and (2) based on Dodd v. Croskey, Defendant preserved his mineral rights. View "Walker v. Shondrick-Nau" on Justia Law

Nile and Katheryn Batman claimed to hold an interest in minerals underlying the properties owned by Wayne Lipperman and the estate of James Albanese (“Albanese”). Albanese and Lipperman filed separate actions seeking to quiet title to their respective properties, claiming that the severed mineral interests held by the Batmans had been abandoned. Albanese and Lipperman also sought to cancel any oil and gas leases executed in relation to the Batmans’ interests in their properties. The trial court granted summary judgment against Albanese and Lipperman. The court of appeals affirmed in both cases. The Supreme Court affirmed, holding (1) the Ohio Dormant Mineral Act (ODMA) applies in these cases; and (2) because neither Albanese nor Lipperman complied with the notice and affidavit requirements in the ODMA, the mineral interests are preserved in favor of their holder, the Batmans. View "Albanese v. Batman" on Justia Law

Plaintiff filed this action against Defendants seeking to quiet title to oil and gas rights under his surface lands and requesting a declaratory judgment, a permanent injunction, and compensation for conversion. The federal district court concluded that its ruling on the parties’ motions for summary judgment required a clarification of two areas of Ohio law and certified these questions to the Supreme Court. The Supreme Court answered (1) the 2006 version of the Dormant Mineral Act, rather than the 1989 version of the Act, applies to all claims asserted after June 30, 2006 alleging that the rights to minerals vested in the surface land holder prior to the 2006 amendments as a result of abandonment; and (2) a payment of a delay rental during the primary of an oil and gas lease is neither a title transaction nor a savings event under the Act. View "Corban v. Chesapeake Exploration, LLC" on Justia Law

Paul Bunting sought a writ of mandamus ordering Tuscarawas County Prosecuting Attorney Ryan Styer to prosecute Thomas Weaver for theft of a motorcycle. The court of appeals sua sponte dismissed the complaint after the prosecutor untimely filed a motion to dismiss. Bunting appealed. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in dismissing the complaint because Styer’s failure to prosecute in this case was not an abuse of discretion, and therefore, Bunting did not have a clear legal right to a writ. View "State ex rel. Bunting v. Styer" on Justia Law

Appellant sought a writ of procedendo requiring Judge Kelly Cottrill to rule on his motion to vacate or set aside the judgment of his conviction. Judge Cottrill had ruled on Appellant’s motion but failed to issue findings of fact and conclusions of law. The court of appeals dismissed Appellant’s petition, finding that the petition was moot. The Supreme Court affirmed, holding that a writ of procedendo was inappropriate because Judge Cottrill did not refuse to enter judgment but, rather, Appellant was dissatisfied with the entry that she issued. View "State ex rel. Poulton v. Cottrill" on Justia Law

In 2016, Defendant was indicted of several offenses. Before trial, the prosecuting attorney obtained a second indictment. The trial court subsequently granted the State’s motion to dismiss the first indictment. Defendant then pleaded guilty to five counts of gross sexual imposition charged in the second indictment. Defendant filed a petition for a writ of habeas corpus arguing that the doctrine of res judicata precluded his convictions because his first indictment was dismissed with prejudice and included the same charges and was based on the same facts and circumstances as the second indictment. The court of appeals dismissed the petition, concluding that Defendant’s argument was a double jeopardy claim and that double jeopardy claims are not cognizable in habeas corpus. The Supreme Court affirmed, holding that because the first indictment was dismissed not on the merits but to prevent a double jeopardy violation, the doctrine of res judicata did not preclude Defendant’s convictions. View "State ex rel. Steele v. Eppinger" on Justia Law

In 2002, Defendant was indicted for murder. After a series of mistrials that were declared in Defendant’s case during the fourteen years since his arrest, Defendant moved to dismiss his indictment, alleging a violation of the Due Process and Double Jeopardy Clauses of the state and federal constitutions. The trial court denied the motion. The court of appeals affirmed, concluding that a mistrial or hung jury does not bar retrial or retrials. Defendant appealed, arguing that yet another trial would violate the “fair play” guaranteed by the Due Process Clause. The Supreme Court affirmed, holding (1) a double jeopardy challenge to the retrial of a defendant following a mistrial is analyzed under the Double Jeopardy Clause rather than the Due Process Clause; and (2) the Double Jeopardy Clause does not bar a defendant’s retrial after several mistrials have been properly declared. View "State v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of murder and aggravated murder. After the mitigation phase and the jury recommendation, the trial court sentenced Defendant to death for the aggravated murder. Defendant appealed, raising twenty-one propositions of law. The Supreme Court rejected each of Defendant’s propositions and affirmed his convictions and sentence of death, holding (1) no prejudicial error occurred during the pretrial phase; (2) there was no prejudicial error in the trial court’s evidentiary rulings; (3) the jury instructions and verdict forms did not violate Defendant’s constitutional rights; (4) cumulative prosecutorial conduct did not violate Defendant’s due process rights; (5) trial counsel provided effective assistance; (6) nothing in the record supported Defendant’s claim of trial court bias; and (7) Defendant’s death sentence was proportionate and appropriate. View "State v. McKelton" on Justia Law

Relator submitted a public-records request to the records clerk for the police department of the City of Avon Lake relating to a police report about a skate-park incident. Relator claimed that he hand-delivered a written request to the clerk on December 30, 2014 and that the police department did not respond to the request until Relator filed this original action for a writ of mandamus on February 5, 2015. The department, in response, asserted that Relator never submitted a written request. The Supreme Court denied Relator’s request for a writ because the only documents requested but not produced no longer existed, and therefore, the case was moot. View "State ex rel. Pietrangelo v. Avon Lake" on Justia Law

Relators filed petitions proposing the adoption of county charters in Athens, Meigs, and Portage Counties. Each of the boards of elections reviewed the petitions and, while determining that the petitions contained sufficient signatures, rejected the petitions as invalid. Secretary of State Jon Husted denied Relators’ protests and instructed the boards not to place the proposed charters on the ballot. Relators then initiated this action seeking a writ of mandamus requiring Husted and the boards of elections to place the proposed charters on the ballot. The Supreme Court denied the writ, holding that the secretary of state and boards of elections did not abuse their discretion in determining that the proposed county charters failed to satisfy the requirements under Ohio Const. art. X, 3 for a valid charter initiative. View "State ex rel. Coover v. Husted" on Justia Law